National Disability Institute welcomes a new Congress who we stand ready to help better understand the economic challenges facing our nation’s over 50 million individuals with disabilities and their families.

As National Disability Institute continues to push forward to build a world where people with disabilities have equal opportunity to achieve financial capability and independence as people without disabilities, the drive to advance economic certainty and a better economic future for all Americans remains a priority for our nation. Much progress needs to be made in these areas, as a 2013 report by the Financial Industry Regulatory Authority (FINRA) found that nearly 1 in 5 Americans spent more than they earned the previous year and another 56 percent lacked the financial capacity to cover emergency expenses or weather the financial storm that comes with losing a job.

In 2014, NDI published an additional report on the financial capability of adults with disabilities that utilized FINRA data that had not been previously analyzed about our target audience (2014 NDI Report). People with disabilities were more likely to be unbanked, unable to cover monthly expenses, and dependent on nonbanks for borrowing that further increased their debt.

While these statistics are certainly troubling, the reality for individuals living with a disability is even more financially alarming. 1 in 3 Americans with a disability live in poverty and have difficulty navigating the web of federal disability programs. In fact, federal government reports continue to highlight the fragmentation of federal disability programs and the lack of alignment of policy goals that define common outcomes. In addition, too many public benefits (Social Security, Medicaid) require as a condition of eligibility that people with disabilities stay poor and prohibit saving and building assets - causing them to fall further and further behind their fellow Americans.

To overcome these challenges, NDI makes the following recommendations to improve tax and social policy and cross-agency collaboration. Join us in our work to advance solutions that promote a better economic future for people with disabilities and their families.

Cross-Agency Coordination

Challenge

No one federal agency has lead responsibility to build financial capability and improve positive financial behavior for individuals with disabilities and their families. Almost one in three working age adults with disabilities live in poverty.

Opportunities

Publish final rules to implement the Achieving a Better Life Experience (ABLE) Act that encourages active participation by states and offers individuals with disabilities and their families multiple investment options for savings in an ABLE account that is easy to set up. NDI will be actively involved in offering suggestions that help shape the regulations regarding eligibility, documentation of expenses, and limitations to Medicaid payback. NDI will also provide assistance to all states to establish ABLE programs.

Push for passage of the Savings for Working Families Act, which would increase the number of available Individual Development Accounts (IDAs) to an estimated 900,000 for low income workers including individuals with disabilities. IDA beneficiaries establish asset goals such as buying a home, starting a business, or getting additional education and must participate in financial education programs. IDAs would be funded by contributions from financial institutions who would receive a tax credit. The IDA beneficiary has his or her savings matched in a tax exempt account which will not impact eligibility for various public benefits.

Expand the IRS community partnership development and volunteer tax preparation assistance programs (on-site and virtual) to support the Volunteer Income Tax Assistance Act (VITA), which would increase funding for volunteer tax preparation programs.

Support passage of the Equal Employment for All Act, which would prevent employers from using credit report scores to deny a job seeker the opportunity to compete for employment. Credit reports bear no relationship to job performance and may adversely impact applicants with disabilities who have credit scores impacted by medical expenses and related debt.

Support changes to the Earned Income Tax Credit (EITC) that lowers the age of eligibility from 25 to 21 and increases the amount of the benefit for individuals who are not part of families with children. Such a change would impact thousands of individuals with disabilities who are not

No one federal agency has lead responsibility to build financial capability and improve positive financial behavior for individuals with disabilities and their families. Almost one in three working age individuals with disabilities lives in poverty.

Opportunities

Publish final rules for the Workforce Innovation and Opportunities Act (WIOA) that encourages states and local Workforce Investment Boards to integrate financial capability supports and services into career and supportive services for job seekers with and without disabilities with the collaboration of WIOA partners and other service delivery systems.

Continue to pilot and test the integration of financial stability strategies in human and social service programs through the use of Innovation and Demonstration Funds across federal agencies.

Workforce Development

Vocational Rehabilitation

Medicaid

Centers for Independent Living

Peer Support - Mental Health (MH) Block Grants

Education (K-12, postsecondary)

HUD Family Self-Sufficiency Program

Establish, by Executive Order, an Interagency Federal Task Force on Economic Empowerment for working age-individuals with disabilities to identify barriers and propose solutions to federal policies that create disincentives to work, saving and asset-building.

Make Changes to Social Security

Challenge

The current rules of eligibility for SSI and/or SSDI creative disincentives to work, saving, and building assets. Current utilization of work incentives including the Ticket to Work program is low with limited awareness and understanding by beneficiaries.

Opportunities

Reform asset limits to determine eligibility under SSI and Medicaid, as well as exclude as assets all restricted savings vehicle such as IRAs, 401(k) and 529 plans.

Encourage the expansion of Plans for Achieving Self-Support (PASS) and similar tools to foster focused asset development and financial planning among the more than 12 million recipients of SSI and SSDI in an effort to help design, customize and accomplish financial goals on an annual basis based upon individual needs and preferences

Offer all SSI and/or SSDI recipients access to financial coaching and links to resources to improve their financial capability and plan for a better economic future.

Consider a gradual decrease in SSDI benefits based on work activity above the SGA limit rather than the cash cliff which SGA employment currently represents.

Make SSA Benefits and Work Incentive advisement services a part of the Workforce Development system, since many work oriented SSA beneficiaries access the services of America’s Job Centers and there is an increasing number who are becoming Employment Networks (ENs).

Improve Consumer Education and Protection

Challenge

People with disabilities as a group are more likely to be victims of financial scams and abuse than their non-disabled peers. As a group they are also less likely to see a financial advisor and more likely to use nonbank financial services with higher interest rates for short and longer term borrowing.

Opportunities

Amend the Workforce Investment Act to require all American Job Centers to offer financial education programs in collaboration with Treasury, the FDIC, and the Consumer Financial Protection Bureau (CFPB).

Amend Individual Plan requirements under IDEA, the Rehabilitation Act (VR), and Home and Community Based Service Waiver (Medicaid) to require annual consideration of the need for financial capability skills development and objectives to advance economic self-sufficiency.

Monitor and influence implementation of the Affordable Care Act in order to prevent further financial destabilization for persons with disabilities.

Establish an Office of Disability within the Consumer Financial Protection Bureau under the Consumer Education and Engagement division and fund pilot projects that build promising practices in the delivery of affordable and accessible financial services and the improved financial capability of youth and adults with disabilities.

Monitor the Direct Express program at the Department of the Treasury to advocate for elimination of bank fees on mandatory debit card use for Social Security beneficiaries who are unbanked.

Implement comprehensive financial education in grades K -12 and at the college and university level, and include persons with disabilities.